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Multinational companies that engage in intra-group financing transactions (IGFTs) are confronted with increasing scrutiny of such transactions by the various governmental and regulatory bodies of the jurisdictions in which they operate. The documentation requirements, which vary by jurisdiction, are complex. This article, the first of three on the subject of transfer pricing requirements for IGFTs, provides a practical overview of the requirements that apply in Luxembourg. The two future articles will address more technical aspects of compliance in Luxembourg.
On January 28, 2011, the Luxembourg tax authorities (Administration des Contributions Directes du Grand Duch de Luxembourg) published an administrative circular, the Transfer Pricing...
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